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Letter to DOE on Programmatic Review of LNG Export Program

In January, the White House announced a pause on LNG export approvals for the Department of Energy to update its underlying analyses for authorizations, which underpin its public interest determinations. In particular, the announcement notes that DOE’s economic and environmental analyses are outdated and calls for them to be updated.

This letter offers recommendations for updating DOE’s analyses. In particular, to ensure a robust public interest analysis that rationally weighs the impacts of export approvals, we urge DOE to:

  • Compare the benefits and costs of further LNG exports against one another, including macroeconomic and climate impacts.

  • Update its analysis of climate costs by:

    • Considering new data in assessing lifecycle emissions;

    • Rigorously assessing gas export’s impacts on global energy supply and demand, including using the federal government’s available substitution models;

    • Monetizing climate effects using the latest climate-damage valuations from the U.S. Environmental Protection Agency (EPA), which reflect the best available science and economics; and

    • Incorporating rational assumptions about the uptake of downstream carbon capture technology.

  • Update its analysis of macroeconomic impacts by:

    • Quantifying the distribution of consumer welfare benefits and costs;

    • Updating its energy-market projections using expert elicitation; and

    • Refining its estimation of gas supply and demand elasticities.

  • Conduct a robust environmental justice analysis that considers the impacts of LNG export terminals on affected communities using the best available methods. 

  • Rescind its categorical exclusion for LNG exports.